MIPS Mastery is a seven-part series on optimizing performance under the Merit-Based Incentive Payment System, originally produced by PYA.
What is the APM Scoring Standard?
One of CMS’ key considerations in drafting the MIPS rule was eliminating duplicative reporting requirements. Because Clinicians participating in certain Medicare APMs already are required to submit specific data (e.g., the 33 MSSP quality measures), CMS created an APM scoring standard to allow for the use of that data to generate a CPS. The APM scoring standard is slightly different than the standard MIPS CPS calculation: 50% weight for quality, 30% for advancing care information, and 20% for clinical practice improvement activity. Note that CMS does not consider the resource use category for MIPS APM entities. Each individual TIN (within the APM entity) is responsible for the advancing care improvement and clinical practice improvement activities reporting as a group. Those APMs that CMS has deemed eligible for the APM scoring standard are referred to as MIPS APMs. For 2017, the list of MIPS APMs includes all of the advanced APMs listed above (remember, QPs and Partial QPs still are subject to MIPS reporting requirements) as well as Track 1 MSSP ACOs and Oncology Care Model one-sided risk arrangements. Just as all MSSP participants now are excused from PQRS reporting requirements (and thus avoid the current 2% penalty for non-reporting), Clinicians who are members of a group listed as a participant in a MIPS APM as of December 31, 2017, will not be subject to separate MIPS reporting for that year. One can expect this will create a significant incentive for providers to participate in a Track 1 MSSP ACO, even though it does not qualify as an advanced APM.
What Mechanisms Will Be Available for Individuals and Groups to Report Scores on Performance Measures?
As is the case with PQRS, individuals and groups will have multiple channels through which to report on performance measures. The proposed rule details the specifications for each reporting option and establishes reporting timeframes. As a general rule, reporting must be completed during the first quarter of the year following the performance year. CMS is strongly encouraging the use of Qualified Clinical Data Registries (QCDRs) and electronic health records (EHRs) for various reporting requirements. That encouragement comes in the form of bonus points for the quality and advancing care information components when measures are submitted through these mechanisms. Other mechanisms include Part B administrative claims,
the CMS Web Interface, and other qualified registries.